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Suppose a client of yours has been assessed penalties for failing to file her tax return and paying tax due timely for the prior year.

Suppose a client of yours has been assessed penalties for failing to file her tax return and paying tax due timely for the prior year. Her unextended return was eventually filed and tax paid in late November after a very long and serious illness kept her hospitalized for most of the year. Prepare a letter to the IRS requesting abatement of the late payment and filing penalties based on reasonable cause. State any assumptions in your letter.

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